Blood, Sweat, and Fears (Part II)

The first part of our series on blood-borne pathogens covered the basics, ending by touching on Universal Precautions and minimum personal protective equipment or PPE. Part two picks up where we left off and delves into the OSHA BBP standard a little further by examining the elements of an Exposure Control Plan more closely

Developing an Exposure Control Plan (ECP) and the elements it should address — Exposure determination, communicating hazards to employees, and recordkeeping, among others

The first article ended by touching on Universal Precautions and minimum personal protective equipment or PPE. In our second part of the series we want to pick up where we left off and delve into the OSHA BBP standard a little further by examining the elements of an ECP more closely.

Potential exposure presents a risk to laboratory employees working with biohazards, especially those whose research or work involves human body fluids, such as those in the medical research or the health care industry. Preventing exposure begins with knowing and following the Centers for Disease Control and Prevention’s universal precautions,1 the assumption that all fluids are infectious, and preventing contact by use of appropriate personal protective equipment such as gloves, lab coats, and eye protection. Additional measures might entail face shields or respirators, depending on the activity.

In 2000, Congress passed the Needlestick Safety and Prevention Act2 (NSPA) that led OSHA to revise its BBP standard. Though most of these revisions are applied to health care settings, it is important to note the emphasis on engineering controls and improved equipment design such as needleless systems for the collection or withdrawal of body fluids. The NSPA mandated changes to the OSHA standard regarding the exposure control plan as well. It requires an annual review and update to reflect changes in technology that reduce exposure to blood-borne pathogens and to consider use of effective safer medical devices to eliminate or minimize occupational exposure.

With the NSPA and its revisions in mind, let’s take a closer look at the Exposure Control Plan, where everything begins in implementation of OSHA’s BBP standard, 40 CFR 1910.1030.3 In the first article we mentioned that the ECP must address 1) exposure determination, 2) communication of hazards to employees, 3) compliance methods, and 4) record keeping. We discussed the first two at length and said that the key to the BBP standard is in the methods of compliance section. So, let’s start there. Compliance methods begin with the application of Universal Precautions, which by now we know by heart, right? Next we get to engineering and work practice controls. As with most OSHA standards and best practices for employee health and safety, engineering controls and work practices take precedent. Controls to eliminate or minimize employee exposures are always the first means of protecting workers. Where exposures remain following installation of controls, personal protective equipment must be used. The OSHA standard requires that these controls be regularly inspected and maintained to ensure their effectiveness.

Hand-washing facilities are examples of proper engineering controls. All laboratory workers know that we wash our hands immediately after removing gloves or following contact with blood or other potentially infected material (OPIM). Employers must provide these hand-washing facilities or, if that is not feasible, an effective antiseptic cleanser with clean towels or antiseptic towelettes. Sharps containers are another example of engineering controls. Immediately or as soon as possible after use, contaminated sharps such as needles and scalpels are placed in puncture-resistant, labeled, and leak-proof containers. Reusable sharps are separated for reprocessing. We all know, and for good reason, to never attempt recapping, bending, or breaking of contaminated needles or other sharps unless we use a one-handed technique or a mechanical device designed to accomplish this.

While on the subject of sharps, it is worthwhile to mention another revision to OSHA’s BBP standard required by NSPA. This one pertains to record keeping and mandates establishing a sharps injury log for the recording of percutaneous injuries from contaminated sharps. The employer must record and maintain information in the sharps injury log while protecting the confidentiality of the injured employee. At a minimum the sharps injury log shall contain:

The type and brand of device involved in the incident

The department or work area where the exposure incident occurred

An explanation of how the incident occurred

Work practices, like engineering controls, offer effective exposure elimination if they are followed. Employees must receive the training on the facilities’ work practices, commit to adhering to them, and know that management supports their use and will audit compliance with appropriate consequences when work practices are not followed. One common work practice is to ensure that all procedures involving blood or other potentially infectious materials are performed in such a manner as to minimize splashing, spraying, spattering, and generation of droplets of these substances. Another is to prohibit eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses in work areas where there is a reasonable likelihood of occupational exposure. Most facilities will not allow food and drink to be kept in refrigerators, freezers, shelves, cabinets, or on countertops or benchtops where blood or other potentially infectious materials are present.

One more work practice rule running a close second to the golden rule of Universal Precautions is the prohibition of mouth pipetting/suctioning of blood or other potentially infectious materials. Although this practice is easily controlled by supplying and using mechanical pipettes, and most would consider it common knowledge today, lab training should still cover this important safety precaution.

Be sure to look for our final installment of this series, where we discuss housekeeping, waste handling, and exposure incident/postexposure procedures. Remember: Safety First.

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